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ARTICLE · 11 MARCH 2024

PAGA Claims Can't Be Tossed On Manageability Grounds

Manatt, Phelps & Phillips, LLP
Manatt, Phelps & Phillips, LLP
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Do trial courts have the inherent authority to dismiss a claim under the Private Attorneys General Act (PAGA) on the grounds of manageability?...

United StatesEmployment and HR
Manatt, Phelps & Phillips, LLP
Manatt, Phelps & Phillips, LLP

Do trial courts have the inherent authority to dismiss a claim under the Private Attorneys General Act (PAGA) on the grounds of manageability?

No, the unanimous California Supreme Court recently concluded.

Royalty Carpet Mills operated two California facilities, one of which Jorge Luis Estrada worked at. He filed a complaint against Royalty alleging various claims, including that the employer violated Labor Code provisions requiring that it provide meal breaks and another seeking PAGA penalties for various alleged Labor Code violations.

Estrada and another Royalty employee subsequently filed a second amended complaint; a third amended complaint that added another 11 named plaintiffs was later filed that alleged a total of seven class claims including PAGA claims.

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